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NIOSH Draft White Paper

NIOSH Investigation into the Issues Raised

in Comment 1 from SCA-TR-TASK1-005

Author – Brian Gleckler

Revision 0

March 5, 2014

This white paper has been generated to support the

NIOSH Response to Comment 1 in SCA-TR-TASK1-0005 
March 5, 2014, Rev 0 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

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or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

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March 5, 2014, Rev 0 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

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NIOSH Investigation into the Issues Raised

in Comment 1 from SCA-TR-TASK1-005

1.0 PURPOSE

The purpose of this white paper is to summarize the results of an investigation that was 

performed by NIOSH in regards to the assessment of the routine airborne releases at the Idaho 

National Laboratory (INL). The results of this investigation are intended to assist NIOSH with 

its response to Comment 1 in SCA-TR-TASK1-0005 (SC&A 2006). 

2.0 SUMMARY OF RESULTS

In general, NIOSH has determined that the key issues that were raised in SCA-TR-TASK1-0005 

(SC&A 2006), regarding the assessment of the routine airborne releases at the Idaho National 

Laboratory (INL), do not interfere with the ability to perform dose reconstructions. 

3.0 BACKGROUND

Comment 1 was made in regards to the information provided in Revision 00 of the document 

titled Technical Basis Document for the Idaho National Engineering and Environmental 

Laboratory (INEEL) – Occupational Environmental Dose (ORAUT 2004). Even though the 

current version of this document is Revision 02, Comment 1 is still considered to be a valid 

comment, since no significant changes have been made to the environmental intakes that were 

previously reported in the technical basis document (ORAUT 2004, 2010). However, it should 

be noted that the title of this technical basis document has been changed to Technical Basis 

Document for the Idaho National Laboratory and Argonne National Laboratory West – 

Occupational Environmental Dose for Revision 02 (ORAUT 2010). In addition, to simplify 

identifying and/or referring to this technical basis document (TBD) in the subsequent sections of 

this white paper, all versions of this document will be referred to as the environmental TBD. 

3.1 Summary of the Issue

Comment 1 as stated in the INL Issue Resolution Matrix for Findings and Key Observations (i.e. 

Attachment 5 of SCA-TR-TASK1-0005) (SC&A 2006). 
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Issue 1: (5.1.1.1) Routine Airborne Releases - Source terms provided require 

improvement for use in determining the worker intake from airborne releases at 

different INL facilities. The data NIOSH uses do not take into account the 

deficiencies in the environmental monitoring equipment and their locations, and, in 

addition, NIOSH does not assess the uncertainties associated with the 

meteorological dispersion model used for the INL site. Most importantly, the 

source terms do not account for worker inhalation of resuspended contaminated 

soils and materials around the INL facilities.

Sections regarding Comment 1 that are in the main body of the INL site profile review (i.e. 

Sections 5.1.1.1.1, 5.1.1.1.2, and 5.1.1.1.3 of SCA-TR-TASK1-0005) (SC&A 2006). Note that 

the portions of Sections 5.1.1.1.1 and 5.1.1.1.2 that were merely quoting other documents have 

been omitted in this document for brevity, and the omitted portions are denoted by “(QUOTED 

PORTION OF ANOTHER DOCUMENT OMITTED)”. 

5.1.1.1.1 Completeness and Quality of Release Data Used

(1) The INELHDE [Idaho National Engineering Laboratory Historical Dose 

Evaluation] report uses effluent release data primarily from stack monitoring and 

air sampling systems installed across the INL site. There were a total of 23 air 

samplers; 12 within the site, and 11 outside the INL boundaries. The INELHDE 

claims: 

(QUOTED PORTION OF ANOTHER DOCUMENT OMITTED)

The ambient air monitors at various INL site locations had been found to be 

deficient in meeting the siting requirements specified in 40 CFR 58 (near 

obstructions) and meeting minimum flow rate for particulates specified in 40 CFR

50 (e.g., 2.5 cfm versus 39 cfm), as cited in a DOE report, Tiger Team 

Assessment of the Idaho National Engineering Laboratory, DOE/EH-0178, 1991 

(DOE-HQ 1991). NIOSH should evaluate the adequacy of the stack release data 

for use in the TBD. The Tiger Team report states the following: 

(QUOTED PORTION OF ANOTHER DOCUMENT OMITTED)

Radiological effluent sampling and monitoring systems throughout INL facilities 

had not been evaluated to ensure that they would detect, quantify, and respond 

adequately to unplanned releases (DOE-HQ 1991). Also, airborne effluent 
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particulates from INL operations had not been adequately characterized, and 

measurements and sampling techniques did not ensure a representative sample for 

effluent monitoring systems (DOEHQ 1991). Several quotations from the Tiger 

Team report illustrate these deficiencies (and point to areas that NIOSH should 

investigate further): 

(QUOTED PORTION OF ANOTHER DOCUMENT OMITTED)

Given these deficiencies in the INL stack monitoring and air sampling systems 

identified by the DOE Tiger Team audit, it is unlikely that the INELHDE results 

would be complete and representative of the actual effluent releases from 

different INL facilities. This would further impact the quality and the validity of 

the dose assessments. NIOSH should evaluate the uncertainties associated with 

these issues, so that the recommended worker intake values from environmental 

releases would be truly claimant favorable. In 2003, SC&A performed a study of 

radioactive release source terms for two major INL programs for the CDC (SC&A 

2003). This study reviewed stack monitoring data and uncertainties associated 

with the data. SC&A provided this report to NIOSH for use in the preparation of 

the INL Site Profile. 

(2) During the site expert interview conducted by SC&A, INL environmental staff indicated 

that other unplanned (episodic) releases occurred at different facilities that are not 

included in the INELHDE. Therefore, they are also not included in the NIOSH TBD. 

For instance, there was an incident at the INTEC (ICPP) in the early 1990s where 

particulate releases were observed as a result of a new steam cleaning process of the CPP 

stack. The airborne material released was believed to be Cs-137 attached to white 

insulation material. Measurable radioactivity was associated with these releases. This 

information is not included in the TBD for the use of dose reconstructions. 

5.1.1.1.2 Dispersion Model 

The Environmental TBD uses a mesoscale model (MESODIF), which employs an 

objective regional trajectory computational scheme, combined with the Gaussian 

diffusion equation for a continuous point source, to estimate dispersion for transport 

of releases. It is a forward timemarching Gaussian plume model in which 

successive, small plume elements (or puffs) are advected throughout the 

computational area. The following quotations, taken from the INELHDE (DOE 

1991a), describe the use of the mesoscale dispersion data from MESODIF model 

for the calculations of average ground level air concentrations at INL facilities: 
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Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

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(QUOTED PORTION OF ANOTHER DOCUMENT OMITTED)

MESODIF is a trajectory model that specifically requires spatial information 

describing upper boundary layer meteorological conditions. INL, however, does 

not have a real-time database that could be used in defining model trajectories. This 

caused significant uncertainties in accurately estimating the dispersion of released 

materials. This deficiency was noted in the DOE-HQ 1991 Tiger Team report 

(DOE-HQ 1991), a contemporaneous report of the INELHDE: 

(QUOTED PORTION OF ANOTHER DOCUMENT OMITTED)

First, the mesoscale model used by INL in the INELHDE is only appropriate for 

evaluating dispersion coefficients for locations at greater than 20 km distance, and 

is not appropriate for those facilities that are within 20 km of each other. It is 

definitely not suitable for determining dispersion of airborne releases within several 

hundred feet from a facility building or a stack. Many INL facilities, however, are 

within 20 km from each other. Second, even for facilities located more than 20 km 

from each other, the dispersion coefficients calculated by this model are deficient 

and not representative. Third, and most important, the workers considered in this 

site profile are more impacted by the release plumes at the facility where they 

worked than those from more distant facilities; this mesoscale model is not capable 

of addressing such short distance dispersion coefficient factors. NIOSH should reexamine the validity of the mesoscale model data used in the occupational 

environmental TBD. 

5.1.1.1.3 Other Observations 

NIOSH should list the routine airborne release activities and associated 

uncertainties for each INL facility in the Occupational Environmental Dose TBD. 

This data would be helpful for the dose reconstructors to assess whether the worker 

intakes are applicable to the claim they are considering. An example would be 

useful, showing how the worker exposure could be calculated using the release 

activities, uncertainty values, and weighting factors. 
March 5, 2014, Rev 0 

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Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

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Page 7 of 32

3.2 Actions from 2011 Working Group Meeting 

NIOSH: Revisit meteorological dispersion model, especially for relatively close proximity to 

release points. 

4.0 NIOSH INVESTIGATION RESULTS

This investigation primarily reevaluated the appropriateness of the meteorological dispersion 

model that was used to estimate the environmental intakes in the environmental TBD and 

investigate the issues raised about exposures that occurred relatively close to a given release 

point. Secondary issues regarding the workers’ inhalation of resuspended radioactivity and 

deficiencies in the INL’s environmental monitoring equipment were also investigated. 

4.1 Investigation of the Meteorological Dispersion Model 

The environmental TBD utilized dispersion isopleths that were obtained from the Idaho National 

Engineering Laboratory Historical Dose Evaluation (INELHDE) to estimate annual average 

environmental air concentrations from stack emissions for each of the major operating areas on 

the INL site (ORAUT 2010, DOE 1991a, DOE 1991b). The dispersion isopleths in the 

INELHDE were generated using the MESODIF dispersion model, which is a mesoscale 

diffusion model that is valid for distances up to about 150 km (DOE 1991a). NIOSH has 

investigated the claim in Comment 1 of SCA-TR-TASK1-0005 (SC&A 2006) that “the 

mesoscale model used by INL in the INELHDE is only appropriate for evaluating dispersion 

coefficients for locations at greater than 20 km distance, and is not appropriate for those facilities 

that are within 20 km of each other”, and has not found evidence to that effect. The MESODIF 

model wasn’t limited to distances of 20 km or greater, it was one of the first models capable of 

modeling atmospheric dispersion beyond 20 km. 

The applicable distances for most atmospheric dispersion models are dependent on the applicable 

distances for the atmospheric dispersion coefficients being used (i.e. the σx, σy, and σz parameters 

being used). Detailed technical information regarding the MESODIF model is provided in the 

NOAA Technical Memorandum ERL ARL-44 (Start et al. 1974). For the σy parameter, 

MESODIF uses the two equations in Figure 1. For the σz parameter, MESODIF uses the 

equation in Figure 2. 
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document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

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Figure 1 – Horizontal Dispersion Coefficient (σy) from ERL ARL-44 (Start et al. 1974) 
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Figure 2 – Vertical Dispersion Coefficient (σz) from ERL ARL-44 (Start et al. 1974) 

In Figure 1, Equation 5a clearly indicates that the MESODIF model is applicable for distances 

less than 20 km. NIOSH also attempted to research the basis for the σy and σz parameters to 

determine if there was a minimum applicable distance associated with the σy and σz parameters. 

The NOAA Technical Memorandum ERL ARL-44 (Start et al. 1974) indicates that the two σy

equations came from the 1968 version of Meteorology and Atomic Energy (Slade 1968). The 

two σy equations in Figure 1 could not be located in the 1968 version of Meteorology and 

Atomic Energy (Slade 1968). The NOAA Technical Memorandum ERL ARL-44 (Start et al. 

1974) also indicates that the “stability-category dependent coefficient of proportionality” and the 

exponents in the two σy equations came from the σy curves in the document IDO-12048, titled 

Climatography of the National Reactor Testing Station (Yanskey et al. 1966). Similarly, the 

NOAA Technical Memorandum ERL ARL-44 (Start et al. 1974) indicates that the “stabilitycategory dependent coefficient of proportionality” in the σz equation came from the σz curves in 

IDO-12048 (Yanskey et al. 1966). IDO-12048 (Yanskey et al. 1966) indicates that curves for 

effluent releases with a 3 to 10 minute duration are based on the graphs in the document titled 

Graphs for Estimating Atmospheric Dispersion (Hilsmeier et al. 1962), which were based on 

Pasquill’s original graphs, and that the that curves for effluent releases with a 15 to 60 minute 

duration are based on the graphs in the document titled Methods of Estimating Air Pollutant 

Dispersion Over Relatively Smooth Terrain from Routine Meteorological Observations (Markee

1963). Based on the starting distances on those graphs, the minimum applicable distance for the 

atmospheric dispersion coefficients being used by MESODIF is at least 100 m (0.1 km). In 

addition, when distance ranges for dispersion coefficients are specified they are typically just the 

distance ranges that the dispersion estimates are based, and not a specification of applicability. 

Therefore, the dispersion coefficients being used MESODIF may be applicable to distances less 

than 100 m (328 ft). 

4.2 Dispersion of Airborne Releases within Several Hundred Feet of Release Point

NIOSH has also investigated the claims in Comment 1 of SCA-TR-TASK1-0005 (SC&A 2006) 

that “It is definitely not suitable for determining dispersion of airborne releases within several 

hundred feet from a facility building or a stack.” and “...the workers considered in this site 

profile are more impacted by the release plumes at the facility where they worked than those 

from more distant facilities; this mesoscale model is not capable of addressing such short 

distance dispersion coefficient factors.” Based on the findings discussed in Section 4.1 above, 

NIOSH determined that the MESODIF model is suitable for determining the dispersion of 

airborne releases at distances of 100 m to 150 km from their release points. No information was 

found to indicate that the MESODIF model is suitable for determining the dispersion of airborne 
March 5, 2014, Rev 0 

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or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

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Page 10 of 32

releases within 100 m (328 ft) of their release points. However, NIOSH has also determined that 

the contribution to the environmental air concentrations from stack releases within 100 m of the 

receptor are not likely significant. 

The Supplement to Technical Basis Document 4 for the Idaho National Engineering and 

Environmental Laboratory: INEEL Occupational Environmental Dose (environmental TBD 

supplement) indicates that with the exception of the Aircraft Nuclear Propulsion Project’s 

releases, the vast majority of the INL’s operational radioactive airborne effluent releases were 

from the Idaho Chemical Processing Plant (ICPP), Test Reactor Area (TRA), and Experimental 

Breeder Reactor-II (EBR-II) areas, in that order (Peterson 2004). The ICPP has 2 significant 

radioactive airborne effluent release points; the 76.2 m high main stack and the 50 m high 

Fourinel Dissolution Process & Fuel Storage (FAST) stack (CDC 2002). The majority of the 

radioactive airborne effluents at the TRA were released via the main stacks for each of the 

TRA’s three reactors, all three were 76.2 m stacks; the majority of the radioactive airborne 

effluents at EBR-II were released via its 61 m main stack (CDC 2002). 

As previously indicated, the environmental TBD utilized dispersion isopleths that were obtained 

from the INELHDE to estimate annual average environmental air concentrations from the annual 

stack emissions for each of the major operating areas on the INL site using the MESODIF 

dispersion model (ORAUT 2010, DOE 1991a). The operational releases were treated as 

occurring at a uniform rate over the year (DOE 1991a). Dispersion isopleths were calculated by 

NOAA for a ground-level elevation assuming that the INL’s total annual airborne effluent was 

released from a 76 m stack midpoint between the ICPP and TRA (Peterson 2004). Figure 3 is a 

map of the INL site, which shows where the various operating areas were located on the site. 

Because the dispersion isopleths were not generated by modeling the actual release points for the 

INL’s radioactive airborne effluents and because the modeled airborne effluent release point was 

over 100 m from any routinely occupied location, the concern that the workers are more 

impacted by the release plumes at the facility where they worked than those from more distant 

facilities is not applicable to the environmental TBD. 

With the exception of fumigation conditions, which only occur about 1% of the calendar year at 

the INL (DeMarrais et al. 1960), the minimum travel distance for a plume originating from a 

stack to reach the ground is when σz equals the stack height. As indicated in Figure 2 above, the 

vertical dispersion coefficients being used by the MESODIF model are based on the σz curves in 

IDO-12048 (Yanskey et al. 1966). Using the σz curves in that document and the release height 

used for the dispersion calculations, one can determine what the shortest travel distance for a 

plume originating from the modeled release point to reach the ground is. 
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or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

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Page 11 of 32

Figure 3 – Map of INL Site (Hoff et al. 1987) 

SOUTH 

SECURITY GATE

▪ 

▪ 

▪ CERRO GRANDE

FRENCHMAN’S

 CABIN

▪ 

RENO RANCH

As previously indicated, the dispersion isopleths were based on the assumption that the INL’s 

total annual airborne effluent was released from a 76 m (250 ft) stack midpoint between the ICPP 

and TRA. Figures 4 and 5 are the σz curves from IDO-12048 (Yanskey et al. 1966) with the 
March 5, 2014, Rev 0 

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document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

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Page 12 of 32

modeled stack height and minimum travel distances depicted on them. Figure 4 is the σz curves 

for 3-15 minute releases and Figure 5 is the σz curves for 15-60 minute releases. Based on those 

curves the minimum travel distance for a plume originating from a stack to reach the ground is 

over 300 m (984 ft). Therefore, it is unlikely that the INL workers were more impacted by the 

release plumes at the facility where they worked than those from more distant facilities. In 

addition, Figures 4 and 5 demonstrate that the MESODIF model was not exceeding its 

minimum applicable distance when the dispersion isopleths, which were used for the 

environmental TBD, were generated. 
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or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

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March 5, 2014, Rev 0 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

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Figure 4 – Vertical Dispersion Coefficients from IDO-12048 for 3 to 15 

Minute Releases (Yanskey et al. 1966) 

Figure 5 – Vertical Dispersion Coefficients from IDO-12048 for 15 to 60 

Minute Releases (Yanskey et al. 1966) 
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4.3 Worker Inhalation Attributable to Resuspension of Contamination

NIOSH has also investigated the claim in Comment 1 of SCA-TR-TASK1-0005 (SC&A 2006) 

that “...the source terms do not account for worker inhalation of resuspended contaminated soils 

and materials around the INL facilities.” NIOSH agrees that the source terms used to estimate 

the INL workers’ environmental intakes did not include potential contributions from resuspended 

contaminated soils and materials around the INL facilities. However, NIOSH has found nothing 

to indicate that those contributions were significant relative to the contributions from the stack 

emissions. 

A review of the environmental air monitoring data provides supporting evidence that the 

resuspension of contamination was not a significant contribution to the onsite environmental air 

concentrations. Figure 4-4 in the environmental TBD provides a comparison of the summarized 

onsite and offsite environmental air concentrations for the years of 1978–1986. The summarized 

data in Figure 4-4 of the environmental TBD and the more detailed data in the INL’s 

environmental monitoring reports show a close correlation between the onsite and offsite 

environmental air concentrations, with the only exceptions being from episodic release events at 

the INL site. If resuspension was a significant contributor to the environmental air 

concentrations at the INL site, one would expect the differences between the onsite and offsite 

environmental air concentrations to be more significant than what they are. 

In addition, the contributions to the INL workers’ internal doses from intakes of resuspended 

environmental radioactivity would be limited for the following reasons. When contamination is 

deposited on the soil, it usually becomes attached to the larger soil particles (DOE 1994). 

Because a significant fraction of the soil particles have an aerodynamic equivalent diameter 

(AED) of > 10 μm, most of the soil particles are not considered to be respirable. Also, the 

radionuclides deposited at the INL were typically beta-gamma emitters, which contribute to the 

internal dose much less than alpha emitting radionuclides. 

The only reports that were found that attributed elevated environmental air concentrations to the 

resuspension of contaminated soils were two of the environmental monitoring data reports (the 

report for the 4th quarter of 1974 and the report for the 1st quarter of 1975) (Walker 1975a, 

Walker 1975b). The environmental monitoring data report for the 4th quarter of 1974 indicated 

that the higher gross beta radioactivity during the 4th quarter of 1974 at the Experimental Breeder 

Reactor-I (EBR-I) and Experimental Field Station (EFS) sampling locations “was probably the 

result of primarily of atmospheric discharges of particulate radioactivity at ICPP with some 

contribution from radioactivity contamination in the soil near the sampling location” (Walker 
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1975a). Figure 6 in an excerpt of Highlights Section from that quarterly report, and Figure 7 is 

a map depicting the onsite environmental air monitoring locations at the INL site. 

Figure 6 – Excerpt of the Highlights Section of the Environmental Monitoring 

Data Report for 4th Quarter of 1974 (Walker 1975a) 
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Figure 7 – Onsite Environmental Air Monitoring Stations 

The environmental monitoring data report for the 1st quarter of 1975 attributed the higher gross 

beta radioactivity measured at EBR-I and the Naval Reactor Facility (NRF) during the 1st quarter 

to the resuspension of radioactive contamination on the soil near the sampling locations. 

Figure 8 in an excerpt of Highlights Section from that quarterly report. 
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Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

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Figure 8 – Excerpt of the Highlights Section of the Environmental Monitoring 

Data Report for 1st Quarter of 1975 (Walker 1975b) 

NIOSH has determined that resuspension was not likely a significant contributor to the elevated 

environmental air sample results at the EBR-I and EFS sampler locations during late-1974 and 

early-1975 for the following reasons. 

1) The elevated environmental air sample results for EBR-I and EFS from late-1974 and 

early-1975 were within the annual fluctuations of the background sampling location for 

1974–1975, so the elevated results could have just been localized fluctuations in the 

levels of background radioactivity. Figures 9 and 10 depict this for EBR-I and 

Figure 11 depicts this for EFS. 

2) The quick return to normal air concentrations indicates that the surface contamination 

causing the elevated air concentrations was mitigated. Given that it is unlikely that the 

surface contamination would have been naturally mitigated within such a short period of 

time and given that no reports of any decontamination work could be found for the 

months immediately after these elevated measurements, it’s unlikely that the 

resuspension of surface contamination was the primary cause of the elevated air 

concentrations. 

3) Onsite environmental air samplers for other locations also had elevated air concentrations 

for the same period (e.g. CFA, ITSA/RWMC, NRF, PBF/SPERT, TAN, and TRA), but 

the elevated results from those locations weren’t attributed to resuspension and don’t 

appear to have been factored into the assumption that was made about the cause of the 

elevated results. Table 1 provides a summary of the environmental air concentrations for 

the EBR-I, EFS, CFA, ITSA/RWMC, NRF, PBF/SPERT, TAN, TRA, and Idaho Falls air 

monitoring locations for the 4th quarter of 1974 and the 1st quarter of 1975. 

Table 1
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Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

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Summary of Environmental Air Monitoring Results

for Selected Monitoring Locations (μCi/ml)a

Locationsb 4th Quarter 1974 1st Quarter 1975

Oct Nov Dec Jan Feb Mar

EBR-I 3.2E-13 2.7E-13 4.6E-13 3.3E-13 3.4E-13 3.2E-13

EFS 2.1E-13 2.3E-13 2.4E-13 2.2E-13 2.4E-13 2.4E-13

CFA 1.9E-13 2.0E-13 2.0E-13 2.0E-13 2.1E-13 2.2E-13

ITSA/RWMCc 2.1E-13 2.1E-13 1.8E-13 1.9E-13 2.2E-13 2.7E-13

NRF 1.8E-13 2.7E-13 1.8E-13 NAd 2.1E-13 2.3E-13

PBF/SPERT 2.7E-13 1.9E-13 1.8E-13 1.8E-13 1.9E-13 2.2E-13

TAN 1.4E-13 1.9E-13 1.6E-13 1.7E-13 1.6E-13 2.0E-13

TRA 1.8E-13 2.7E-13 1.8E-13 1.9E-13 1.8E-13 2.2E-13

Idaho Falls 1.3E-13 1.4E-13 1.3E-13 2.0E-13 2.3E-13 2.3E-13

Notes:

a - The values in this table were obtained from the graphs in the Environmental Monitoring Data Reports 

for the 4th quarter 1974 and 1st quarter 1975 (Walker 1975a, Walker 1975b). 

b - The EBR-I and EFS locations are the locations where the elevated air concentrations were attributed to 

resuspension. The locations following them are other locations with elevated air concentrations (i.e. 

above the offsite/background sampling location). The Idaho Falls location is the offsite/background 

sampling location.

c - The Environmental Monitoring Data Report for the 2nd quarter of 1974 indicates that the ITSA 

sampling location is associated with the burial grounds (Walker 1974). Beginning with the 1975 

reports, the ITSA sampling location appears to have been renamed as the RWMC location (Walker 

1975a, Walker 1975b).

d - NA – not available. 

The elevated January 1975 result for the NRF sampling location appears to have been due to a 

single hot particle of Ru-106 that was on the weekly sample collected during the first week of 

January 1975. This is indicated in Figure 8 and Figure 12. Figure 12 is a graphical depiction 

of monthly results for the NRF sampling location. It should also be noted that exposures 

received at the NRF are not covered under the EEOICPA, because it is a facility used exclusive 

for the Naval Nuclear Propulsion Program. 
March 5, 2014, Rev 0 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 20 of 32
March 5, 2014, Rev 0 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 21 of 32

Figure 9 – CY-1974 - Monthly Gross Beta Environmental Air Concentrations at EBR-I and 

Background Location at Idaho Falls (Walker 1975a) 
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Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 22 of 32
March 5, 2014, Rev 0 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

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Figure 10 – CY-1975 - Monthly Gross Beta Environmental Air Concentrations at EBR-I 

and Background Location at Idaho Falls (Sill 1976)
March 5, 2014, Rev 0 

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Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 24 of 32
March 5, 2014, Rev 0 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 25 of 32
March 5, 2014, Rev 0 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 26 of 32

Figure 11 – CY-1974 - Monthly Gross Beta Environmental Air Concentrations at EFS and 

Background Location at Idaho Falls (Walker 1975a)
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Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 27 of 32
March 5, 2014, Rev 0 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 28 of 32

Figure 12 – CY-1975 - Monthly Gross Beta Environmental Air Concentrations at NRF and 

Background Location at Idaho Falls (Sill 1976)
March 5, 2014, Rev 0 

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Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

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4.4 Deficiencies in Environmental Monitoring Equipment

NIOSH acknowledges that there were deficiencies regarding the number of and the locations of 

the INL’s environmental air sampling stations. However, those deficiencies were likely what 

prompted the original author of the environmental TBD to estimate the environmental intakes 

from the stack releases versus the air concentrations measured by the environmental air sampling 

stations. Because the environmental air sampling data was not used to estimate the 

environmental intakes in the environmental TBD, any deficiencies with the environmental 

monitoring equipment are not relevant to the environmental TBD. 

5.0 CONCLUSIONS & RECOMMENDATIONS

In general, NIOSH has determined that the key issues that were raised in SCA-TR-TASK1-0005 

(SC&A 2006), regarding the assessment of the routine airborne releases at the INL, do not 

interfere with the ability to perform dose reconstructions. NIOSH has confirmed that the 

MESODIF dispersion model is applicable for distances less than 20 km. Based on the 

atmospheric dispersion coefficients being used by the MESODIF model, the minimum 

applicable distance for the MESODIF model is at least 100 m (0.1 km). NIOSH has also 

determined that the contribution to the environmental air concentrations from stack releases 

within 100 m of the receptor are not likely significant. 

In regards to worker inhalation attributable to the resuspension of contamination, NIOSH agrees 

that the source terms used to estimate the INL workers’ environmental intakes did not include 

potential contributions from resuspended contaminated soils and materials around the INL 

facilities. However, NIOSH has found nothing to indicate that those contributions were 

significant relative to the contributions from the stack emissions. In addition, a review of the 

environmental air monitoring data provides supporting evidence that the resuspension of 

contamination was not a significant contribution to the onsite environmental air concentrations. 

In regards to the deficiencies with the INL’s environmental monitoring equipment, NIOSH 

determined that any deficiencies with the environmental monitoring equipment are not relevant 

to the environmental TBD, because the environmental air sampling data was not used to estimate 

the environmental intakes in the environmental TBD. 
March 5, 2014, Rev 0 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 30 of 32

6.0 REFERENCES

CDC (U.S. Centers for Disease Control and Prevention), 2002, Identification and Prioritization 

of Radionuclide Releases from the Idaho National Engineering and Environmental 

Laboratory, RAC Report No. 3-CDCTask Order 5-2000-FINAL, Department of Health 

and Human Services, October 8. [SRDB Ref ID: 1141] 

DeMarrais, G. A., and N. F. Islitzer, 1960, Diffusion Climatology of the National Reactor Testing 

Station, IDO-12015, U.S. Weather Bureau, Idaho Falls, Idaho, April. [SRDB Ref ID: 

117233] 

DOE (U.S. Department of Energy), 1991a, Idaho National Engineering Laboratory Historical 

Dose Evaluation, DOE/ID-12119, Volume 1, Idaho Operations Office, Idaho National 

Engineering Laboratory, Idaho Falls, Idaho, August. [SRDB Ref ID: 1107] 

DOE (U.S. Department of Energy), 1991b, Idaho National Engineering Laboratory Historical 

Dose Evaluation, DOE/ID-12119, Volume 2, Idaho Operations Office, Idaho National 

Engineering Laboratory, Idaho Falls, Idaho, August. [SRDB Ref ID: 1109] 

DOE (U.S. Department of Energy), 1994, DOE Handbook – Airborne Release Fractions/Rates 

and Respirable Fractions for Nonreactor Nuclear Facilities, Volume I – Analysis of 

Experimental Data, DOE-HDBK-3010-94, Volume I, Washington, D.C., December. 

[SRDB Ref ID: 56569] 

Hilsmeier, W. F., and F. A. Gifford, Jr., 1962, Graphs for Estimating Atmospheric Dispersion, 

ORO-545, U.S. Department of Commerce, Division of Technical Information, Weather 

Bureau Research Station, Oak Ridge, Tennessee, July. 

Hoff, D. L., E. W. Chew, and S. K. Rope, 1987, 1986 Environmental Monitoring Program 

Report for the Idaho National Engineering Laboratory Site, DOE/ID-12082(86), U.S. 

Department of Energy, Idaho Operations Office, Idaho National Engineering Laboratory, 

Idaho Falls, Idaho, May. [SRDB Ref ID: 1673] 

Markee, E. H. , Jr., 1963, Methods of Estimating Air Pollutant Dispersion Over Relatively 

Smooth Terrain from Routine Meteorological Observations, presented at the 219th

National Meeting of the American Meteorological Society at Palo Alto, California, 

June 20. 
March 5, 2014, Rev 0 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

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Page 31 of 32

ORAUT (Oak Ridge Associated Universities Team), 2004, Technical Basis Document for the 

Idaho National Engineering and Environmental Laboratory (INEEL) – Occupational 

Environmental Dose, ORAUT-TKBS-0007-4, Rev 00, Oak Ridge, Tennessee, March 30. 

[SRDB Ref ID: 19518] 

ORAUT (Oak Ridge Associated Universities Team), 2010, Technical Basis Document for the 

Idaho National Laboratory and Argonne National Laboratory West – Occupational 

Environmental Dose, ORAUT-TKBS-0007-4, Rev 02, Oak Ridge, Tennessee, January 8. 

[SRDB Ref ID: 78635] 

Peterson, H. K., 2004, Supplement to Technical Basis Document 4 for the Idaho National 

Engineering and Environmental Laboratory: INEEL Occupational Environmental Dose, 

March 9. [SRDB Ref ID: 15451] 

SC&A (S. Cohen & Associates), 2006, Review of the NIOSH Site Profile for the Idaho National 

Laboratory, Idaho, SCA-TR-TASK1-005, January 25. 

Sill, C. W., 1976, INEL Site Environmental Monitoring Data – Fourth Quarter 1975, U.S. 

Energy Research and Development Administration, Idaho Operations Office, Health 

Services Laboratory, Idaho Falls, Idaho, March 4. [SRDB Ref ID: 1502] 

Slade, D. H. (ed.), 1968, Meteorology and Atomic Energy 1968, TID-24190, U.S. Department of 

Commerce, Environmental Science Services Administration, Air Resources Laboratories, 

Silver Springs, Maryland, July. [SRDB Ref ID: 118302] 

Start, G. E., and L. L. Wendell., 1974, Regional Effluent Dispersion Calculations Considering 

Spatial and Temporal Meteorological Variations, ERL ARL-44, U.S. Department of 

Commerce, National Oceanic and Atmospheric Administration, Air Resources 

Laboratories, Idaho Falls, Idaho, May. [SRDB Ref ID: 105387] 

Yanskey, G. R., E. H. Markee, Jr., and A. P. Richter, 1966, Climatography of the National 

Reactor Testing Station, IDO-12048, U.S. Department of Commerce, Environmental 

Science Services Administration, Air Resources Field Research Office, Idaho Falls, 

Idaho, January. [SRDB Ref ID: 12736] 

Walker, D. I., 1974, INEL Environmental Monitoring Data – Second Quarter 1974, U.S. Energy 

Research and Development Administration, Idaho Operations Office, Health Services 

Laboratory, Idaho Falls, Idaho, October 17. [SRDB Ref ID: 125269] 
March 5, 2014, Rev 0 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. This 

report has been reviewed for Privacy Act information and has been cleared for distribution. NOTICE: This report 

has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 32 of 32

Walker, D. I., 1975a, INEL Environmental Monitoring Data – Fourth Quarter 1974, U.S. 

Energy Research and Development Administration, Idaho Operations Office, Health 

Services Laboratory, Idaho Falls, Idaho, June 18. [SRDB Ref ID: 88447] 

Walker, D. I., 1975b, INEL Environmental Monitoring Data – First Quarter 1975, U.S. Energy 

Research and Development Administration, Idaho Operations Office, Health Services 

Laboratory, Idaho Falls, Idaho, August 7. [SRDB Ref ID: 87417] 

Walker, D. I., 1976, INEL Site Environmental Monitoring Data – Fourth Quarter 1975, U.S. 

Energy Research and Development Administration, Idaho Operations Office, Health 

Services Laboratory, Idaho Falls, Idaho, March 4. [SRDB Ref ID: 1502]